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Limitations on the Terms of Consumer Credit Extended to Service Members and Dependents
Dear Sir or Madam:
The undersigned trade associations (the Associations) appreciate the opportunity to offer our views on the advance notice of proposed rulemaking (ANPR) recently issued by the Department of Defense (Department). The ANPR seeks comment on whether the Department should consider revising existing protections under the Military Lending Act which apply to consumer credit extended to members of the armed forces and their dependents.
The Associations have worked closely with the Department over the last several years and appreciate this opportunity to ensure appropriate safeguards are in place to protect servicemembers and their dependents while avoiding steps that segregate military families or deny them access to needed and beneficial products and services. The Associations greatly value the service and sacrifices of the members of our armed services and their families and want to work collaboratively with the Department to ensure servicemembers at all stages of their careers as well as their families have appropriate access to credit and to the tools and skills necessary to make informed decisions about financial products and services.
As discussed in detail below, the Associations believe that the Military Lending Act as implemented by the regulation issued by the Department of Defense is working as intended to protect members of the armed forces and their dependents. Imposing additional requirements on lending to servicemembers would have adverse consequences for members of the armed forces and military families. While added restrictions are not needed, a proactive step the Associations support is strengthening financial education for servicemembers at all phases of their career since financial education plays a critical role helping servicemembers and their families use credit products wisely.
To read the full Comment Letter, download the PDF.